Last updated 31-05-2022
The purpose of this document is to provide a privacy notice for individuals that complies with data protection law. The notice relates to your personal data that the Eaton Gate group may collect and hold, how you can expect your personal data to be used and for what purposes, and your rights to this data and information.
2. Policy Statement
The Group is committed to protecting the privacy and security of your personal information.
This privacy notice describes how we collect and use personal information about you during and after your working relationship with us. This notice is intended to be consistent with all applicable legal and regulatory requirements regarding its subject matter. It applies to all the Group’s employees, workers and contractors.
The Eaton Gate group company which offers to or provides the intermediary insurance services or activities to you is primarily responsible for the personal data collected in relation to that offer or service and acts as the “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection law to notify you of the information contained in this privacy notice.
This privacy notice applies to any individual to whom the personal data relates. This privacy notice does not form part of any contract of employment or other contract to provide services. We may update this privacy notice at any time.
It is important that:
- you read this privacy notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing information containing personal data about you, so that you are aware of how and why we are using such information.
- the information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
3. Detailed Procedures
3.1 Data Protection Principles
We will comply with data protection law. This says that the personal information we hold about you must be:
- used lawfully, fairly and in a transparent way.
- collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- relevant to the purposes we have told you about and limited only to those purposes.
- accurate and kept up to date.
- kept only as long as necessary for the purposes we have told you about.
- kept securely.
3.2 Information and data
Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
There are “special categories” of more sensitive personal data which require a higher level of protection.
We will collect, store, and use the following categories of personal information about you (or that of any other persons insured):
- Personal contact details such as title, name, addresses (including proof of addresses), telephone numbers, email addresses, date and place of birth, gender, marital status and dependants and family details
- Next of kin and emergency contact information
- Details about your existing lifestyle and insurance arrangements including information from publicly available sources such as the electoral roll, British Geological Survey, information about previous and current insurance claims and telematics data
- Employment details including job titles, the start date, location of employment or workplace, work history, working hours, training records and professional memberships, salary, pension and benefits information
- Nationality and identification numbers issued by government bodies or agencies or other publicly available information including national insurance number, passport number, tax identification number, driving licence number and vehicle registration details
- Bank account details, or payment card details, income or other financial information such as payroll records and tax status information
- Credit and anti-fraud data including credit history, credit score and sanction list searches
- Information about your use of our information and communications systems, including IP address
We may also collect, store and use the following “special categories” of more sensitive personal data which we need to collect in order to assess the risk to be insured and provide an insurance quote
- Information about your political opinions or whether you are a politically exposed person
- Information about your health, including any medical condition, health and sickness records
- Information about criminal convictions and offences
3.3 How information is collected
We collect your personal data from various sources including, yourself, your family members, employer or representative; third party insurance intermediaries; insurers; reinsurers; credit reference agencies; anti-fraud databases, sanctions lists, court judgements and other databases; government agencies; or in the event of a claim, third parties including the other party to the claim, witnesses, experts (including medical experts), loss adjustors, solicitors, and claims handlers.
3.4 How we use your information
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we have entered into with you.
- Where we need to comply with a legal obligation.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
We may also use your personal data in the following situations, which are likely to be rare:
- Where we need to protect your interests (or someone else’s interests).
- Where it is needed in the public interest or for official purposes.
We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal data to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal data are listed below.
- Providing a quote or processing your application to purchase an insurance policy, its fulfilment or other related service
- Managing and administering products and services that we supply including underwriting, reinsurance, claims handling and providing legal advice and services
- Notifying you about changes to our service
- Claims handling or procuring this from any appointed service provider and business partner
- Administering the contract we have entered into with you, including for debt recoveries
- Investigating and resolving any complaints you have about our services or those provided by our appointed service providers and business partners.
- Helping us to monitor and manage products operational and governance services, including to develop new and innovative products and services
- Providing you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes
- Business management and planning, including accounting and auditing
- Education, training and development requirements
- Dealing with legal disputes involving you
- To prevent or detect fraud and check your identity to prevent money laundering
- To monitor, or procuring this from any appointed service provider, your use of our information and communication systems to ensure compliance with our IT business control policies
- To ensure, or procure this from any appointed service provider, network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal data.
We will use your particularly sensitive personal information in the following ways:
- We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits.
- We envisage that we will hold information about criminal convictions. We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you in the course of you working for us.
We do not need your consent if we use special categories of your personal data in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive special category data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
3.4.1 If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).
3.4.2 Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
3.5 Automated Decision Making
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
- Where we have notified you of the decision and given you 21 days to request a reconsideration.
- Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
- In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
We may use automated tools with decision making to assess applications for insurance such as price rating rules, flood, theft and subsidence area checks and credit checks. Our business partners may do this for claims handling processes. When calculating insurance premiums, we may compare personal data against industry averages or use this to create the industry averages going forwards. These automated decisions will produce a result on whether we are able to offer insurance, the appropriate price for policies or whether we can accept claims. If the individual objects to an automated decision, we may not be able to offer the insurance quotation or renewal.
If we make an automated decision on the basis of any particularly sensitive special category personal data, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
3.6 Data sharing
We may have to share your data with third parties, including third-party service providers and other entities in the Group. We require third parties to respect the security of your data and to treat it in accordance with the law. We may transfer your personal data outside the EU. If we do, you can expect a similar degree of protection in respect of your personal data.
3.6.1 Why might you share my personal information with third parties?
We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
3.6.2 Which third-party service providers process my personal data?
“Third parties” includes third-party service providers and business partners (including contractors and designated agents) and other entities within the Group. The following activities are carried out by third-party service providers: insurance and reinsurance underwriting and administration, claims handling services, IT services, management and storage of data and data analytical services, organisations and public bodies including the Police, fraud prevention agencies and databases, conduct of market research and services to more effectively communicate with you. We can supply on request further details of these third parties we access or contribute to and how this information may be used. If you require further details contact email@example.com.
3.6.3 How secure is my information with third-party service providers and other entities in the Group?
All our third-party service providers and other entities in the Group are required under written agreements to take appropriate security measures to protect your personal data in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
3.7 Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
3.8 Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal data in accordance with applicable laws and regulations.
3.9 Rights of Access, Correction, Erasure and Restriction
Under certain circumstances, by law you have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data to another party.
If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact firstname.lastname@example.org in writing.
3.9.1 No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
3.9.2 What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
3.10 Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact email@example.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
3.11 Data Protection Officer
We have appointed a data protection officer to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal data, please contact the firstname.lastname@example.org.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
3.12 Changes to this Privacy Notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.
If you have any questions about this privacy notice, please contact email@example.com.
Last updated 31-05-2022
What are cookies?
Cookies are small files that websites place on the device you’re using to browse the site. Cookies are commonly used to record some aspect of your visit to a site, such as choices you’ve made or preferences you’ve set during your visit.
Keeping your personal data safe
Our cookies do not store personal data such as your name, address, phone number or email in a format that can be read by others. The cookies we use cannot read or search your computer, smartphone or web-enabled device to obtain information about you or your family, or read any material kept on your hard drive.
We do use a small number of cookies that store encrypted versions of information where you have asked us to, such as the ‘Remember me’ function that allows us to remember your Account username for subsequent visits. However, this is encrypted so that only the Group can read this information. The website that places a cookie owns that cookie. This means only that website and other sites that it has agreed to share information with can read the information stored using a cookie.
Links to sites provided by others
If you follow a link from our website to another website, please be aware that the owner of the other website will have their own privacy and cookie policies for their site. We recommend you read their policies as we are not responsible or liable for what happens at their site.
How to manage and switch off cookies
Your web browser provides settings that allow you to manage or switch off cookies. If you do switch off cookies, remember that you may not be able to use all of the services on our websites.
You can find out more about managing and switching off cookies at the independent website: allaboutcookies.org.
The types of cookies we use on this site –
1. Strictly necessary cookies
These cookies are essential for our online services and tools to work. They collect or record information that we need to make our site work.
Common uses for this type of cookie include:
- storing information so that shopping baskets can be provided
- storing information for e-billing
- allowing users to log in or access private areas of a site.
These cookies only last for a single browsing session – when you leave our site, they are removed.
2. Performance cookies
These cookies help us to monitor and improve how our website works.
Common uses for this type of cookie include:
- collecting information about which pages visitors go to most often
- noting if visitors get any error messages from web pages
- understanding which links visitors like to follow (including adverts) and which they choose not to.
The information collected using these cookies is anonymous and cannot be used to identify an individual visitor.
3. Functionality cookies
These cookies allow us to provide you with enhanced features that need to remember your preferences and choices, such as your user name, language or region. They also let us monitor how our website is performing so we can keep on improving it.
Common uses for this type of cookie include:
- providing you with local information, such as health providers in your area
- remembering how you like to use our site, such as what text size you like or what media software you use
- remembering what topics you’re interested in so we can provide you with related products, services and information.
The information we store in these cookies is encrypted so that only we can read it.
4. Targeting and advertising cookies
These cookies are sometimes referred to as retargeting cookies and are placed by the Group or by advertising networks that the Group work with. These cookies remember that you have visited our site as well as what interested you on our site, such as the pages you viewed.
We use these cookies to ensure that he advertising and website content that we serve you, on our site or other websites, is aligned to your browsing habits. For example, to remind you of the products or services you have shown an interest in. These cookies are also used to limit the number of times you may see an advert/content and to tailor the messaging we serve you. They may also be used for market research and to help measure the effectiveness of an advertising campaign.
You can find out more about managing and switching off cookies at the independent website: allaboutcookies.org.